We would like to remind our clients of a few items to consider with respect to their NRD filing obligations, so that filings are made (and approved) as quickly as possible.
When filing a new individual registration on Form 33-109F4 – Registration of Individuals and Review of Permitted Individuals (F4), it is important to disclose in Item 1.2 – Use of Other Names whether or not you use a “nickname” or short form name (e.g., “Jay” for “Jason”). In our experience, this question is often raised by regulatory staff when they come across a name other than the legal name in the application package and could lead to delays.
Another housekeeping item to remember when completing an F4 relates to disclosure of past employment history. While Item 11 of the F4 requires that disclosure of previous employment and other activities during the last 10 years be included in Schedule H, the Schedule itself indicates that if you were employed or had business activities in the securities or derivatives industry, those jobs and activities must also be disclosed, even if they are outside the 10-year window.
If you have any questions about navigating the registration process in a practical manner, please contact us.
September 30, 2021